Privacy Policy

1. Scope of this Privacy Policy

1.1. Scope. Our Privacy Policy applies to the data you provide and that is collected when you create an account, publish listings, exchange messages, browse or make any use of the Sites.

1.2. Exclusions. This Privacy Policy does not apply to third-party websites, even if you access them through links contained on the Sites.

ERA is not responsible for these websites and their content and does not share, endorse, monitor, validate or accept the way such websites or content storage tools collect, process and transfer your personal information.

We recommend that you consult their respective privacy policies to be properly informed about how your personal information is used by other websites or tools.

2. Information collected, received and stored

The following information is collected, received and stored by ERA:

  • a) Account information. When you create an ERA account or otherwise interact on the Sites, we collect certain information, such as your name, email address, password, phone number, CPF (Brazilian taxpayer ID) number, identification document, financial information, photos and transactional activity within our platforms;
  • b) Authentication services. If you choose to log in to the Sites through a third-party authentication service, such as Facebook Connect, ERA may also receive and store additional information from your profile or other information authorized by the provider of that service;
  • c) Listing information. When you publish on the ERA website, in addition to the information about the advertised product, some of your profile information will be displayed, such as your name, phone number, date of your last access to the Site, the date your profile was created on the Site and a link to your other listings. Please note that your publications are accessible to third parties and may be listed in search engine results, including in the cache of such search engines, in feeds and on other websites under agreements between them and ERA. You acknowledge that ERA has no control over third-party websites and their indexing;
  • d) Games, advertising and promotions. ERA may collect your personal information when you take part in games, quizzes and other marketing initiatives promoted by us on the Sites and on third-party websites. This information includes views of advertisements on the Sites or on third-party websites;
  • e) Customer service. If you need to contact our customer service department, ERA may collect the personal information necessary to handle your request and contact you, as well as information about your communications with ERA;
  • f) IP addresses, cookies and identifiers. Your IP address and other data related to your connection may be used to personalize our services and help us understand how Users use the Sites. ERA may block access to the Site for Users located in certain countries, identified by IP address. In addition, ERA may collect information to be used on the Sites through technologies such as tags, cookies, pixels, local storage, and a tool for collecting information about phone calls originating from links on the Site, regardless of whether the User is registered.
  • g) Automatically collected information. When you access the Sites or third-party services, ERA may receive and record information from your browser or device on our servers, such as the Android, iOS or other similar operating system Advertising Identifier, as well as location data received from the device's sensors. In addition to this data, we may also collect data about advertising on the device, including clicks made from it, impressions and time spent viewing advertisements. In compliance with transparency requirements, we detail below the device data that may be collected if you use one of our apps:
    • i) Anonymous device advertising identifiers, mobile device attributes and applications installed on the device;
    • ii) Device sensor data;
    • iii) Anonymized device location data via GPS or cellular network.

    Please note that ERA may allow third parties, such as advertising and analytics service providers, to collect any of the information specified in this item using this type of technology directly on the company's websites. To access the list of third parties on our website, please contact our customer service.

  • h) Chat. Communications made through our Chat are not private and messages are stored on ERA's servers;
  • i) Phone calls. The date, time, duration, caller and audio of calls placed by Users through the phone call link available in listings on the Site may be collected;
  • j) Information from credit protection agencies. We may receive and store other information about you, such as information held by credit bureaus or publicly available information, for credit analysis and fraud prevention purposes.

3. Use of Information

Information is collected by ERA as set out in this Privacy Policy in order to provide the service properly. This information is essential to:

  • a)Create and manage accounts you may have with us, verify your identity, provide our services through the Sites, resolve technical issues and enable or disable features;
  • b)Customize offers and experiences on the Site, making your experience with us as personalized as possible, to the extent permitted by applicable law;
  • c)Contact the User, including about service-related matters, customer service or marketing communications;
  • d)Carry out internal operations, including customer support, troubleshooting, data analysis, testing, research and statistics, in order to improve our services;
  • e)Enforce ERA's Terms of Use, including combating fraud and any unlawful activity, and establish, exercise and defend rights;
  • f)As required by applicable laws and regulations; and
  • g)For other purposes for which we provide specific notice at the time of collection, or otherwise as authorized or required by law.

4. Monitoring

ERA may use automated Chat analysis tools for various purposes, with the aim of improving the Sites and the tool.

Among these purposes, the tools may be used to identify, among the messages exchanged between you and other Users in the Chat, any information that may violate, or raise suspicion of violating, the Terms of Use or applicable law.

To this end, human access to messages may be granted, restricted to cases strictly necessary to provide the feature and improve the User experience on the platform, and always in accordance with the applicable Terms of Use and law.

ERA may provide copies of messages to the competent authorities, regardless of notice to Users, for the purpose of cooperating in investigations, inquiries, and judicial or administrative proceedings.

If another User exchanging messages with you (the “Reporting Party”) reports conduct of yours that violates, or shows signs of violating, the Terms of Use or the law, the Reporting Party may voluntarily disclose that communication to ERA.

Whenever one of the parties to a conversation requests the conversation history, ERA may disclose such information.

5. Information Sharing

ERA may share your personal information with other companies in its economic group, with other Users, business partners and service providers that are relevant to enabling the provision of the services. Such sharing takes place according to the following criteria and for the purposes described below:

  • a) ERA Group companies: we may share your information with our affiliates or entities that offer services jointly with us, in any country, which may process this information to help us with the purposes described above, acting under this Privacy Policy;
  • b) Transfer of Assets: If ERA, or a division of ERA, is reorganized or sold and all or substantially all of its assets are transferred to a new owner, your personal information may be transferred to the buyer regardless of your authorization in order to ensure continuity of the services;
  • c) Other Users: sharing of data provided by a User interested in a listing with the advertising User, in order to promote interaction between the parties (for example, an interested User may see the advertising User's contact phone number if the advertising User has chosen to make it visible);
  • d) Third-party service providers: We work with third-party service providers to help us operate, run, improve, understand, customize, support and advertise our services. When we share data with third-party service providers, we require them to use your data in accordance with our instructions and terms or with your express consent, where applicable. For example, requests submitted through the Support page of this website are recorded on the Movidesk (Zenvia) customer service platform, which processes this data on our behalf solely to respond to the ticket;
  • e) Improvement of the Sites: ERA may share data that does not individually identify our Users with third-party service providers, trusted partners or approved researchers, in order to better understand which advertising and services may interest you, to improve the overall quality and effectiveness of our services or theirs, or to contribute to academic research. Data from the tool that identifies information about phone calls originating from links on the Site will be limited to the transcribed content of the recording, as well as characteristics of the identified audio, exclusively for machine learning purposes, without direct access by ERA or the third party.
  • f) Regulatory bodies, judicial or administrative authorities and credit protection agencies: we may share your personal information in order to provide the competent authorities with all information requested regarding the User and the operations they carry out on the Sites. Furthermore, we may share your personal information with public authorities or private entities to combat fraud and abuse on the ERA network, to investigate suspected violations of the law, or to combat any other suspected breach of our Terms of Use or the law;
  • g) With your authorization: In other cases not provided for above, where there is a purpose for sharing personal data and information, we will send you a notification with information about such sharing to request your consent for a specific purpose.

6. User Control

Users are free to choose which information they wish to provide to ERA; however, some of it is essential for the provision of the Services.

6.1. Access, correction and deletion. You can correct or delete any information provided when creating an account or listing by sending an email to the customer service channel or by accessing the “My Account” menu on the Site. The email address provided cannot be changed, and only one email address may be registered per account. If your account was created through an identity provider (e.g. Facebook Connect), you may also disable or change the account information through the settings offered by that identity provider (e.g. on facebook.com).

6.2. Third-party choices. You can disable your ads and the use of information for interest-based targeted advertising.

6.3. Cookies. You can disable cookies in your browser, but please be aware that, if you do so, some tools may not work as well.

6.4. Limiting data collection. If you wish to limit the information ERA collects and stores, you should go to the “My Account” section of the Site and edit the information provided. Some information is necessary and mandatory to enable use of the Site and, by deleting or blocking certain information, your use of the Sites and Services may lose functionality.

7. User Responsibilities

7.1. Information in Listings. Any information Users share in listings is their own responsibility. Users should carefully consider the risks of making certain information — especially personal information, such as a precise address — publicly available in a listing. We recommend that you read our tips and always turn to our Help Center if you face any difficulty or have questions about how to proceed and do business.

7.2. Published Information. Any information Users make available in publicly available profiles or in the Chat (if the User chooses to use this service) is their own responsibility. You should carefully consider the risks of making certain statements or publishing personal information — especially information such as a precise address or location. A User may copy or photograph your messages and circulate them among other Users or outside the Sites. ERA is not responsible for messages or acts of third parties that occur as a result of information you made publicly available to a third party or that you shared with any person or with another User.

8. User Rights

Users have certain rights regarding their personal data and may exercise them by contacting us by email through the customer service channel. These rights are:

  • a) Confirmation that personal data is being processed: Upon the User's request, ERA will confirm whether personal data is being processed, under applicable law;
  • b) Access to personal data: The User may request access to their personal data collected and stored by ERA;
  • c) Correction of incomplete, inaccurate or outdated data: The User may, at any time, change and edit their personal data by logging in to their account;
  • d) Data portability: The User may, upon express request, ask for their data to be ported to another service or product provider. On some occasions, portability may not be carried out in order to protect trade or industrial secrets;
  • e) Data deletion: The User may, at any time, request the anonymization, blocking or deletion of unnecessary or excessive data or data processed in breach of applicable law;
  • f) Information about shared use of data: This Privacy Policy describes ERA's personal data sharing activities. For more information about how we share your data, please contact us.
  • g) Withdrawal of consent: Whenever we request your consent, the User may withdraw it at any time, free of charge and through a simple procedure. The User acknowledges that all processing carried out before the withdrawal of consent remains valid and that the withdrawal request will not result in the deletion of personal data previously processed and retained by ERA on other legal grounds.

9. Children's and Adolescents' Data

ERA does not knowingly collect or store personal data or information of children or adolescents under 18 (eighteen) years of age.

Upon notification or discovery, ERA will make all reasonable efforts to delete or destroy any personal information that may have been collected or stored without our knowledge or consent.

10. Interactions with Third-Party Websites

We may provide links to other websites on the Internet. ERA is not responsible for these websites and their content and does not share, endorse, monitor or validate the way such websites or content storage tools collect, process and transfer your personal and private information.

We recommend that you consult the privacy policies of such websites to be properly informed about how your personal information is used by other websites or tools.

11. End of Processing

This Privacy Policy applies to the circumstances mentioned above for the entire period during which ERA stores your data. We store and retain your information: (i) for the time required by law; (ii) until the end of the processing of personal data, as mentioned below; or (iii) for the time necessary to preserve ERA's legitimate interest. Accordingly, we will process your data, for example, during the applicable limitation periods or for as long as necessary to comply with a legal or regulatory obligation. Throughout this period, this Policy applies.

The processing of personal data will end in the following cases: (i) when the purpose for which the personal data was collected has been achieved, and/or the personal data collected is no longer necessary or relevant to achieving that purpose; (ii) when the User requests the deletion of their data; and (iii) when there is a legal determination to that effect.

When the processing of personal data ends, except in the cases established by applicable law or by this Privacy Policy, the personal data will be deleted and this Policy will no longer apply to your relationship with ERA.

12. Changes to the Privacy Policy

As our business model constantly evolves, ERA reserves the right to change this privacy policy at any time by publishing the updated version on the Sites.

If there is a material change in the processing of personal data, you will be informed and will have the opportunity to review the revised policy before deciding to continue using our services.

13. Identification of the Controller and the Data Protection Officer

ERA SERVIÇOS DE TECNOLOGIA DA INFORMAÇÃO LTDA. (“ERA”), a company registered with the CNPJ/MF under number 26.168.845/0001-84, headquartered at Rua Miguel Pascoal, 104, 1st floor, Room 01, Vila João Jorge, Campinas – SP, ZIP code 13041-312, Brazil, is the multimedia communication services (SCM) company responsible for this Privacy Policy.